The Swiss Federal Department for Economic Affairs, Education and Research (WBF) has published updates to the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), aligning Swiss sanctions with ongoing international restrictions targeting Russia. This matters for Swiss financial institutions as it reinforces asset freezing and economic resource restrictions, heightening compliance risks amid prolonged geopolitical tensions, with the ordinance valid until at least November 2026.
What Changed
The publication announces amendments to SR 946.231.176.72, though specific details in the notice are limited; it signals ongoing refinements to sanctions measures originally enacted on March 4, 2022. Related documentation indicates persistent expansions, such as broader restrictions on Russian energy sector activities (e.g., prohibiting certain services, financing, and transactions), definitions encompassing financial instruments like derivatives, crypto-assets, and securitizations, and prohibitions on asset management or use except for normal administrative actions by financial institutions.
What You Need To Do
- Block prohibited activities in energy sector, financial services (e
- Update internal policies, screening tools, and training to reflect changes; maintain records of compliance checks and authorizations (if applicable under Article 11)
- Monitor FINMA's sanctions page for full ordinance text and related guidance
Key Dates
January 13, 2026 - Publication of amendments by WBF, triggering immediate review obligations.
Various historical dates (e.g., March 25, 2022 at 23:00; January 25, 2023 at 18:00) - Prior amendment effective dates, illustrating pattern of rapid implementation.
November 22, 2026 - Current expiry of ordinance (subject to extension).
Compliance Impact
Urgency: High - Ongoing amendments to this long-standing ordinance (active since 2022) demand immediate screening and blocking to avoid FINMA enforcement, fines, or reputational damage, especially with crypto and energy sector expansions capturing evolving risks. Non-compliance risks asset release violations or facilitation of sanctioned activities, amplified by FINMA's enforcement focus on financial crime.